DCT

2:25-cv-00412

Kohree v. RVLock & Co

Log In

I. Executive Summary and Procedural Information

  • Parties & Counsel:
  • Case Identification: 2:25-cv-00412, D. Utah, 05/23/2025
  • Venue Allegations: Venue is asserted based on Defendant RVLock having a regular and established place of business, including offices and employees, within the District of Utah.
  • Core Dispute: Plaintiffs, a group of e-commerce sellers, seek a declaratory judgment that their recreational vehicle (RV) door lock products do not infringe a patent owned by Defendant.
  • Technical Context: The technology involves integrated electronic lock assemblies for RVs, which combine traditional mechanical paddle handles with electronic keypads and motorized deadbolts.
  • Key Procedural History: The complaint arises from infringement assertions made by the Defendant through the Amazon Patent Evaluation Express (APEX) process, which allegedly resulted in the delisting of Plaintiffs' products. Plaintiffs characterize this as a misuse of the APEX system, giving rise to a justiciable controversy. The patent-in-suit was assigned from Bauer Products, Inc. to Defendant RVLock in September 2023.

Case Timeline

Date Event
2008-12-22 Earliest Priority Date Claimed by ’919 Patent
2015-07-21 U.S. Patent No. 9,085,919 Issues
2023-09-12 ’919 Patent Assignment Executed to RVLock
2025-04-21 RVLock Files Amazon Complaint Against XPORTION-DIRECT
2025-04-22 RVLock Files Amazon Complaints Against YSSKTCTIME and KAW
2025-04-29 RVLock Files Amazon Complaint Against Kohree
2025-05-23 Complaint for Declaratory Judgment Filed

II. Technology and Patent(s)-in-Suit Analysis

U.S. Patent No. 9,085,919 - "Touch Pad Lock Assembly"

  • Patent Identification: U.S. Patent No. 9,085,919, "Touch Pad Lock Assembly," issued July 21, 2015.

The Invention Explained

  • Problem Addressed: The patent describes prior art RV paddle handle assemblies as having certain drawbacks, including the need for separate manual actuation of the latch and deadbolt, a lack of suitability for remote or electronic operation, and a complicated construction that is expensive to manufacture and difficult to repair (’919 Patent, col. 1:44-59).
  • The Patented Solution: The invention is an integrated lock assembly that combines a traditional paddle handle for latch operation with a motor-driven deadbolt that can be actuated electronically via a touchpad. The system is designed to house the handle, latch, deadbolt, motor, and electronics within a single unit, providing both mechanical and keyless electronic security (’919 Patent, Abstract; col. 2:1-27). As shown in the embodiment of Figure 4, a key lock (11) can rotate a lock cam (74), which moves a series of links (83, 87) connected to a motor (86) and a deadbolt (80) to lock or unlock the door.
  • Technical Importance: The technology aimed to modernize RV entry systems by consolidating mechanical and electronic locking functions into a single, self-contained, and user-friendly product for the vehicle market (’919 Patent, col. 1:31-34).

Key Claims at a Glance

  • The complaint asserts non-infringement of independent claim 1 (Compl. ¶29).
  • The essential elements of independent claim 1 include:
    • a housing;
    • an external handle pivotally mounted to the housing;
    • a latch operably connected to the handle to secure a closure;
    • a key lock mounted on the housing;
    • a lock cam rotatably mounted in the housing and connected to the key lock, the lock cam having a crank arm;
    • a first link operably connected with the lock cam crank arm;
    • a deadbolt lock operably connected with the first link;
    • a motor operatively connected with the first link; and
    • an electronic touchpad operatively connected with the motor to shift the deadbolt.
  • The complaint notes that the Accused Locks do not infringe claims that depend from claim 1 (Compl. ¶30).

III. The Accused Instrumentality

Product Identification

  • The accused instrumentalities are various models of RV door locks sold by Plaintiffs Kohree LLC, YSSKTCTIME, XPORTION-DIRECT, and KAW, collectively referred to as the "Accused Locks" (Compl. ¶1). Specific Amazon Standard Identification Numbers (ASINs) are provided for the accused products (Compl. ¶17, 19, 21, 23).

Functionality and Market Context

  • The Accused Locks are described as RV door lock products that are imported, marketed, and sold on the Amazon platform (Compl. ¶1). The complaint includes several images of the Accused Locks, depicting them as integrated units with a handle, a key cylinder, and a numeric keypad. Illustration 1 shows an exemplary Accused Kohree Lock, which is a black, rectangular lock assembly with a handle and a ten-digit keypad (Compl. ¶17). Illustration 2 shows an Accused YSSKTCTIME Lock that includes the lock assembly, physical keys, and a wireless remote fob, suggesting multiple modes of operation (Compl. ¶19). Plaintiffs allege these products have earned significant reputation and customer recognition in the marketplace (Compl. ¶17, 19, 21, 23).

IV. Analysis of Infringement Allegations

The complaint seeks a declaratory judgment of non-infringement. The analysis below summarizes Plaintiffs' allegations that their products lack specific claimed elements.

’919 Patent Infringement Allegations

Claim Element (from Independent Claim 1) Alleged Non-Infringing Functionality Complaint Citation Patent Citation
a latch operably connected with the external handle and configured such that when the external handle is in the retracted position, the latch is in a latched position...and when the external handle is in the extended position, the latch is in an unlatched position... The complaint alleges the Accused Locks do not include a latch configured to operate in the claimed manner in connection with the external handle. ¶30 col. 13:38-48
a lock cam rotatably mounted in the housing and operably connected with the key lock for rotation therewith, the lock cam having a lock cam crank arm; The complaint alleges that in the Accused Locks, the lock cam does not have a "lock cam crank arm." ¶30 col. 13:51-53
a first link operably connected with the lock cam crank arm; The complaint alleges the deadbolt's movement is not driven by a "first link" connected to a crank arm. ¶30 col. 13:54-55
the deadbolt lock being operably connected with the first link; The complaint alleges the operability of the deadbolt is not determined by a "first link" because the Accused Locks do not have one. ¶30 col. 13:60-61
a motor having a locked and unlocked position operatively connected with the first link; The complaint alleges the motor in the Accused Locks is connected to a spur gear rather than a "first link." ¶30 col. 13:62-63
  • Identified Points of Contention:
    • Technical Questions: The central technical dispute concerns the mechanism that connects the motor and key lock to the deadbolt. The complaint alleges the Accused Locks use a "spur gear," while the patent claims a specific series of connections involving a "lock cam crank arm" and a "first link" (Compl. ¶30). The case will require a factual determination of the precise internal mechanics of the Accused Locks.
    • Scope Questions: The primary legal dispute will be one of claim scope. The key question is whether mechanical terms like "first link," "operably connected," and "lock cam crank arm," as defined and illustrated in the ’919 Patent, can be interpreted to cover the "spur gear" mechanism allegedly used in the Accused Locks.

V. Key Claim Terms for Construction

  • The Term: "first link"

  • Context and Importance: This term appears in claim elements 1(f), 1(h), and 1(i) and is central to the claimed power transmission mechanism. Plaintiffs' non-infringement argument hinges on the assertion that their products lack this element entirely, using a "spur gear" instead (Compl. ¶30). The construction of "first link" may be dispositive for a substantial portion of the infringement analysis.

  • Intrinsic Evidence for Interpretation:

    • Evidence for a Broader Interpretation: A party might argue that "link" should be given its plain and ordinary meaning as any component that transmits force or motion between two other parts, which could potentially encompass a gear system.
    • Evidence for a Narrower Interpretation: The specification describes and illustrates a specific structure for the "first link." It is consistently depicted as an elongated, rigid bar (83) that pivotally connects the deadbolt (80) to a motor crank arm (76) (’919 Patent, Fig. 4; col. 7:50-54). A party could argue this specific embodiment limits the term to a pivoting bar-like structure, thereby excluding a rotating gear.

  • The Term: "lock cam crank arm"

  • Context and Importance: This term, recited in claim element 1(e), is the component that allegedly transfers rotational motion from the key lock's cam to the "first link." Plaintiffs explicitly allege their products lack a "crank arm" (Compl. ¶30). Practitioners may focus on this term because its presence or absence is a bright-line factual distinction alleged by the Plaintiffs.

  • Intrinsic Evidence for Interpretation:

    • Evidence for a Broader Interpretation: A party could argue a "crank arm" is any feature of a rotating cam that is offset from its axis of rotation to convert that rotation into reciprocating motion, a functional definition that might be met by a feature of the accused device's cam.
    • Evidence for a Narrower Interpretation: The patent provides a detailed depiction of the "lock cam 74" having a distinct "crank arm 75" (’919 Patent, Figs. 11-12; col. 7:16-18). This specific, articulated structure may support a narrower construction that requires a physically distinct arm, rather than merely an eccentric point of connection on a cam wheel.

VI. Other Allegations

  • Indirect Infringement: The complaint seeks a declaratory judgment that Plaintiffs do not infringe the ’919 Patent either directly or indirectly (Compl. ¶29).
  • Willful Infringement: The complaint does not contain an allegation of willful infringement by the Defendant. However, Plaintiffs request a finding that the case is "exceptional" under 35 U.S.C. § 285, which would entitle them to attorneys' fees (Compl. Prayer for Relief ¶C). This request appears to be based on allegations that Defendant engaged in a "deliberate and systematic pattern of conduct by willfully misusing the Amazon Patent Evaluation Express ('APEX') process" to harm Plaintiffs' business (Compl. ¶15).

VII. Analyst’s Conclusion: Key Questions for the Case

  • A core issue will be one of definitional scope: can the term "first link," which the patent specification illustrates as a pivoting bar, be construed to cover the "spur gear" mechanism that Plaintiffs allege is used in the Accused Locks? The outcome of this and related claim construction questions will likely determine the infringement result.
  • A key evidentiary question will be one of technical operation: what is the precise mechanical structure and function of the internal components of the Accused Locks? The complaint's assertions regarding a "spur gear" and the absence of a "crank arm" will need to be substantiated with evidence during discovery.
  • A central procedural question is whether Defendant's alleged "misuse" of the Amazon APEX process to target Plaintiffs' products constitutes conduct that renders this case "exceptional" under 35 U.S.C. § 285, potentially shifting the burden of attorneys' fees.